Frequently Asked Questions
- Fibre Circle accepts group (holding company) registrations as well as sister (subsidiary) company registrations, even if these are operating divisions.
- It is the prerogative of the registering party whether to register a holding company or its subsidiaries. The latter is the preferable route for Fibre Circle for auditing purposes.
Identified Products and Paper Categories
Paper and paper-based products across seven categories which are either manufactured locally or imported into South Africa.
1. Office paper
- Uncoated woodfree paper, locally manufactured and imported
- Imported recycled office paper
2. Newsprint, magazine and graphic papers
- Printed and Unprinted newsprint
- Imported news-papers
- Imported magazines
- Imported reels of above grades
3. Packaging papers
This includes cardboard primary packaging (containing the actual product) and secondary packaging (typically containing products packaged in primary packaging), and paper packaging which is used for the containment, transport, handling, protection, promotion, marketing or sale of a product.
- Kraft paper
- Card-board boxes
- Printed or unprinted folding boxboard
- Wrapping paper/gift wrap
- Kraft paper bags – grocery bags, takeaway or fast food bags
4. Paper sacks
- Currently recycled (sugar, flour etc.)
- Not recycled currently (potato bags, cement bags)
5. Label backing papers/release liners
Paper based labels, release liners or backing paper and waste matrix.
6. Liquid board packaging (food and beverage cartons)
- Aseptic, long life cartons
- Refrigerated cartons for milk and juice
7. Multi-layer paper-based products
- Paper cups & containers
- Frozen food packaging
- Plastic/barrier coated paper
- If the supplier of office paper does not directly manufacture the paper, do we still require some proof from them that the paper procured is conforming to the EPR regulation? What proof is required?
- Your suppliers must give you proof in the form of a valid certificate of registration and a valid certificate of good standing from the relevant PRO.
- It is also important to consider responsible sourcing in terms of a chain-of-custody and environmental certification such as Forest Stewardship Council or PEFC certification.
A valid certificate of registration and a valid certificate of good standing from the relevant PRO.
- Fibre Circle is responsible for labels and label backing paper that have a greater proportion of paper in their composition than those that don’t. For example, plastic shrink wrap labels are not part of Fibre Circle.
- Importers and manufacturers of labels with backing paper will pay the EPR fee – the EPR fee is paid to Fibre Circle on the entire tonnage of label and backing paper.
Yes, this is because they are not made less recyclable in the conversion process. In addition, the EPR fee will have been paid when the paper was manufactured or imported. Such products will only attract an EPR fee if they are imported as flatpacks or if they are imported as packaging around products and this packaging amounts to more than 10 tonnes per annum.
- When it comes to paper recycling, should citizens separate their paper and paper packaging into different grades?
At home, office and school level, it is often difficult to keep the different types/grades of paper separate for collection unless you have the space and facilities to do so. The sorting of paper recyclables is most likely to happen once the paper has been collected.
You can find a series of posters here that will help you sort your recyclables from non-recyclables.
Volumes and Declarations
We have uploaded a PDF version of the declaration template here.
10 tonnes per annum of paper-based products SOLD to your customers or placed onto the local market.
- If I import more than 10 tonnes per annum, but place less than 10 tonnes on the market, must I still register?
Yes, you should register but in this case you can submit a nil declaration in terms of product placed on the market. (You are not declaring stock, you only declare once it is sold). Please use the import code to assist you in the correct completion of the declaration form.
- Is the minimum threshold of 10 tonnes in place per product category, or a cumulative 10 tonnes over all seven categories?
The 10 tonnes per annum is for cumulative paper and paper packaging aggregated across seven categories.
- Yes this should be declared.
- A few examples can assist here:
- Imported appliances: Each in their folding box board (primary packaging) and the 20 kettles in the cardboard box (secondary packaging), both paper types need to be declared.
- Imported paper on a reel: 4 ton reel of paper that is wrapped in brown kraft paper: the brown kraft should be declared as well as the 4 ton reel.
- Imported A4 office papers: A4 office paper reams are wrapped in multi-layer packaging, 5 reams to a box and shipped in a corrugated cardboard box. All three paper types should be declared.
- In some cases, your customers may request a Fibre Circle certificate of good standing, in which case, register with Fibre Circle, submit a nil declaration* on your volumes and become certified as compliant. (*Locally manufactured papers would already have been EPR levied through your supplier’s registration with Fibre Circle. You are entitled to request a certificate of good standing from them.)
- If you convert the locally sourced paper into product and change its composition into something that is less recyclable (e.g. laminate paper packaging), you will need to register and declare your tonnages.
- As a brand owner how accurate are we expected to be with our reporting? Due to system and process complexity we may never be 100% accurate on the amount of paper or other packaging waste
Fibre Circle suggests you measure each line item, either from suppliers’ data or directly. You can then aggregate based on sales per line items, the paper types, classifications and categories within the the declaration form.
- Does EPR apply only to post-consumer waste and not industrial or pre-consumer waste generated in a factory.
All waste – pre-consumer/industrial and post-consumer – is covered by the EPR regulations. The point of the regulations is to reduce waste to landfill and encourage a circular economy. The EPR fee seeks to augment the recovery and recycling of the backing paper (usually pre-consumer) from a factory and household/business level.
Clause 5. and Clause 5.(1)(a) of the EPR Lgislation refers:
- Extended producer responsibility measures to be implemented by producers – (1) The producer of a product or class of products, as identified by the Minister in terms of section 18 (1) of the Act, must-
(a) establish and implement an extended producer responsibility scheme that includes the entire value chain or join another extended producer responsibility scheme that includes the entire value chain or appoint a producer responsibility organization to establish and implement an extended producer responsibility scheme that includes the entire value chain
There is no other way of ensuring inclusion of “the entire value chain” other than by the pass through of charges.
It is worth noting that in all instances where EPR Legislation has been enacted throughout the world, pass-through is the norm.
- There will be no government subsidy. The EPR fee paid by producers will fund the implementation of the scheme to comply with the requirements of the regulations.
- The requirement of NPC status ensures that the funds are used for their intended purpose and not for profit. Public benefit status means that if donations are made to Fibre Circle, the donor will receive a tax exemption for the donation. Note this is not the case for EPR fees, only for donations for any special CSI projects.